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Methods to verify the identity of persons and entities

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

Overview

This guidance came into effect on June 1, 2021.

This guidance explains the methods that can be used by reporting entities (REs) to verify the identity of a person or an entity.

Note: For specific information on when to verify the identity of a person or an entity (the timing requirement) for your business sector, refer to the related guidance by business sectors.

Who is this guidance for

The requirement to verify the identity of a person or an entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations applies to all reporting entities

Note: Throughout this guidance, references to REs covered under paragraphs 5(a) to (g) of the PCMLTFA include:

In this guidance

Related guidance

1. Meaning of verifying the identity of a person or an entity

It means to use the methods described in this guidance to ensure that the information in an identification document or from other informational sources matches the information that the person or entity provided.

Verifying identity is a foundational element of Canada's anti-money laundering and anti-terrorist financing regime and a key component of an RE's relationship with clients. It helps you to know your clients and to understand and assess any risk that may be associated to their transactions or activities.

2. How to verify the identity of a person

You can use any of the 5 methods described below to identify a person:

  1. 2.1 Government-issued photo identification method
  2. 2.2 Credit file method
  3. 2.3 Dual-process method
  4. 2.4 Affiliate or member method
  5. 2.5 Reliance method

2.1 Government-issued photo identification method

You may verify the identity of a person by referring to a government-issued photo identification document.Footnote 1 To do so, the document must:

Photo identification documents issued by municipal governments, Canadian or foreign, are not acceptable. See Annex 4 for examples of acceptable government-issued photo identification documents.

You can determine whether a government-issued photo identification document is authentic, valid and current by viewing it in person, and by looking at the characteristics of the original physical document and its security features (or markers, as applicable) in the presence of the person being identified. This will allow you to be satisfied that the identification document is authentic, as issued by the competent authority (federal, provincial, or territorial government), valid (unaltered, not counterfeit) and current (not expired).     

Watch video

Video 1– Verifying the identity of a client: Government-issued photo ID method

Using the government-issued photo identification method if a person is not physically present

You may use the government-issued photo identification method if a person is not physically present, but you must have a process in place to authenticate the government-issued photo identification document. For instance, you could assess a document by using a technology capable of determining the document's authenticity. For example, you could:

When a person is not physically present, you must still determine whether the authenticated government-issued photo identification document is valid and current, and that the name and photo are those of the person providing the document. For example, you could:

Note: It is not enough to only view a person and their government-issued photo identification document through a video conference or another type of virtual application.

Your compliance program's policies and procedures must describe the processes you follow to determine whether a government-issued photo identification document is authentic, whether the client is present or not, and how you will confirm that it is valid and current. Your policies and procedures must also describe the steps you use to confirm that the name and photograph are those of the person. Your processes to determine that a government-issued photo identification document is authentic, valid, and current, and the verification step (ensuring that the name and photo match the name and appearance of the person), do not need to happen at the same time. It is up to you to determine the timing, but you must complete both steps.

Record keeping requirements for the government-issued photo identification method

If you use the government-issued photo identification method, you must record:Footnote 3 

2.2 Credit file method

You may verify the identity of a person by referring to information that is in their credit file.Footnote 4 To do so, the credit file must:

A credit file provides a rating on a person's ability to repay loans; however, it is possible to request a credit file to verify a person's identifying information that does not include a credit assessment. You do not need a credit assessment to verify the identity of a person. Equifax Canada and TransUnion Canada are Canadian credit bureaus that provide credit file information for identification purposes.

To use the credit file method, you must conduct the search at the time you are verifying the person's identity. A person cannot provide you with a copy of their credit file, nor can a previously obtained credit file be used.

It is acceptable to use an automated system to match the person's information with the information in the person's credit file. You may also refer to a third party vendor to provide you with valid and current information from the person's credit file. A third party vendor is a business that is authorized by a Canadian credit bureau to provide access to Canadian credit information.

If any of the information provided by the person (name, address or date of birth) does not match the information in the credit file, you cannot use that credit file to verify the identity of the person. You will need to use another credit file from a different provider (credit bureau or third party vendor) or use a different method (for example, the government-issued photo identification method or the dual-process method) to verify the person's identity.

On occasion, information found in the credit file may contain a variation on the name or a discrepancy in the address that was provided to you by the person. In these instances, you must determine whether the information in the credit file matches the information provided by the person. For example:

Watch video

Video 2 – Verifying the identity of a client: Credit file method

Record keeping requirements for the credit file method

If you use the credit file method, you must record:Footnote 6 

Your compliance program's policies and procedures must describe the processes you will follow to verify a person's identity using the credit file method and how you will ensure that the information is valid and current. It should also include the steps you will take if the information is not valid and current (for example, search a different credit file, use another method, stop the transaction, etc.).

2.3 Dual-process method

You may verify the identity of a person by using the dual-process method, which consists of doing any two of the following:Footnote 7

The information you refer to must be valid and currentFootnote 8 and come from two different reliable sources. This information could be found in statements, letters, certificates, forms or other information sources that can be provided through an original version or by another version of the information's original format such as a fax, a photocopy, a scan, or an electronic image. For example, you can rely on a fax, photocopy, scan or electronic image of a government-issued photo identification document as one of the two pieces of information required to verify a person's identity.

You cannot use the same source for the two categories of information you choose to verify a person's identity.Footnote 9 For example, you cannot rely on a bank statement from Bank A that includes the person's name and address and another bank statement from Bank A that includes the person's name and confirms that the person holds a deposit account, as Bank A would be the same source of both categories of information. You can, however, refer to a bank statement from Bank A that contains the person's name and confirms that the person holds a deposit account, and rely on an electronic image of a driver's licence to confirm the person's name and address.

For further precision, the possible combinations for this method include:

Referring to information from one reliable source that includes the person's name and address and confirming that this matches the information provided by the person, and referring to information from a different reliable source that includes the person's name and date of birth and confirming that this matches the information provided by the person.

OR

Referring to information from one reliable source that includes the person's name and address and confirming that this matches the information provided by the person, and referring to information from a different reliable source that includes the person's name and a financial account (specifically, a deposit account, a prepaid payment product account, a credit card account or a loan account) and confirming this information.

OR

Referring to information from one reliable source that includes the person's name and date of birth and confirming that this matches the information provided by the person, and referring to information from a different reliable source that includes the person's name and a financial account (specifically, a deposit account, a prepaid payment product account, a credit card account or a loan account) and confirming this information.

Note: If the information does not match the information provided by the person, you cannot rely on it. For example, it is not acceptable to rely on information if the account number or number that is associated with the information is truncated or redacted. On occasion, information from a source may contain a variation on the name of the client or a typo in the client's address. In these instances, you must determine whether the information matches the information provided by the person. If it is a slight typo in the address or a misspelled name, you may determine that the information still matches what the person provided. However, in the case of an incorrect date of birth, it is more likely that you will determine that the information does not match. In this case, you cannot rely on the information from this source for identification purposes. You must obtain information from a different source under the dual-process method or use a different method (for example, the government-issued photo identification method or the credit file method) to verify the person's identity.

Reliable source of information

A reliable source of information is an originator or issuer of information that you trust. To be considered reliable, the source should be well known and considered reputable. For example, a reliable source could be the federal, provincial, territorial or municipal levels of government, Crown corporations, federally regulated financial institutions, or utility providers. Social media is not an acceptable source of information to verify a person's identity. Also, the source cannot be the person whose identity is being verified, nor you, the RE who is verifying identity.Footnote 10 See Annex 5 for a table of examples of reliable sources of information for the dual-process method.

How to use a credit file under the dual-process method

A Canadian credit file can be used as one of the two pieces of information required to verify the identity of a person under the dual-process method. Specifically, it can be used to confirm the person's name and address, name and date of birth, or to confirm the person's name and confirm that the person has a credit card account or a loan account. If you use a credit file as one of the information pieces for the dual-process method, it must have existed for at least six months.Footnote 11 

Information from a second source, for example, a property tax assessment, must be used to confirm the second category of information. In this instance, the two reliable sources are the Canadian credit bureau that provided the credit file information and the municipal government that issued the property tax assessment. The information from these two sources must match the information provided by the person.

You can also refer to information from a Canadian credit bureau if it acts as an aggregator that compiles information from different reliable sources (often referred to as tradelines). In this instance, the Canadian credit bureau must provide you with information from two independent tradelines where each tradeline confirms one of the two categories of information required to verify the identity of a person under this method. In this instance, each tradeline is a distinct source; the credit bureau is not the source

The tradelines cannot be your own, as the RE verifying the person's identity, and each tradeline must originate from a different reliable source (for example, a federally regulated financial institution, a utility service provider, etc.). 

Watch video

Video 3 – Verifying the identity of a client: Dual-process method

Record keeping requirements for the dual-process method

If you use the dual-process method to verify a person's identity, you must record:Footnote 12

Your compliance program's policies and procedures must describe the processes you follow when using the dual-process method to verify a person's identity and how you will ensure that the information is valid and current.

2.4 Affiliate or member method

You may verify the identity of a person by confirming that one of the following entities previously verified the person's identity:

You must confirm that the name, address, and date of birth in the affiliate or member's records match the information provided by the person whose identity is being verified.Footnote 16

The affiliate or member must have previously verified the person's identity by using the government-issued photo identification method, the credit file method or the dual-process method presented in this Guidance. If the affiliate or member verified the identity of the person prior to June 1, 2021, they must have done so in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), by using the methods that were in place at the time.Footnote 17

If you have any concerns about the methods or information that the affiliate or member used to verify the person's identity, you should re-verify their identity,Footnote 18 as you have the responsibility for ensuring the person's identity has been verified.

Note: Financial services cooperatives or credit union centrals act on behalf of a membership composed of certain financial entities and can provide financial services to that group.

Watch video

Video 4 – Verifying the identity of a client: Affiliate or member method

Record keeping requirements for the affiliate or member method

When you verify the identity of a person by confirming that an affiliate or a financial entity that is a member of your financial services cooperative or credit union central previously verified their identity, you must record:Footnote 19

Note: If the affiliate or the member verified the identity of the person in accordance with the methods that were in place prior to June 1, 2021, you must still record the information listed above, but include the method they used in accordance with the PCMLTFR as it read at the time, and the information that was required to be recorded for that method.Footnote 20

Your compliance program's policies and procedures must describe the processes you follow when using the affiliate or member method to verify a person's identity.

2.5 Reliance method

You may verify the identity of a person by relying on measures that were previously taken by:

To rely on measures previously taken by an affiliated foreign entity, you must be satisfied, after considering the risk of a money laundering or terrorist activity financing offence in the foreign state in which it carries out its activities, that:Footnote 23

To rely on measures previously taken by another RE or an affiliated foreign entity to verify the identity of a person, you must:Footnote 24

Watch video

Video 5 – Verifying the identity of a client: Reliance method

Record keeping requirements for the reliance method

If you rely on another RE or an affiliated foreign entity to verify the identity of a person, you must keep a record of:Footnote 25

Your compliance program's policies and procedures must describe the processes you follow when using the reliance method to verify a person's identity and how you will ensure that the information is valid and current.

3. Using an agent or a mandatary to verify the identity of a person on your behalf

You may verify the identity of a person by using an agent or mandatary to carry out the verification on your behalf, in accordance with the government-issued photo identification method, the credit file method, or the dual-process method.Footnote 26

You may rely on the measures that were previously taken by an agent or mandatary to verify the person's identity, if the agent or mandatary was:Footnote 27

To use an agent or mandatary to verify the identity of a person you must:Footnote 28

Example 1 — Acceptable

Jane Smith would like to open an account with you. Your agent—with whom you have a written agreement for this purpose—verified Jane Smith's identity in 2019 using the government-issued photo identification method, by referring to her driver's licence, which expired in February 2021. In 2019, Jane Smith's name and appearance matched the name and photograph on the driver's licence, and the document was determined to be authentic, valid and current, therefore, her identity was verified by the agent in accordance with the method. Jane's name and appearance have not changed. When you obtain the information from the agent, you are satisfied that the information the agent confirmed as being Jane's (her name and photo) is still valid and current and is therefore acceptable. It does not matter that her licence (the identification document used by the agent) has expired, as it is the information that you must be satisfied is valid and current, not the document.   

Example 2 — Not acceptable

Jane Smith (maiden name — Jane Rogers) would like to carry out a transaction for which you must verify her identity. Your agent—with whom you have a written agreement for this purpose—verified Jane Rogers' identity in 2019 using the government-issued photo identification method, by referring to her driver's licence, which has not yet expired. In 2019, Jane Rogers' name and appearance matched the name and photograph on the driver's licence, and the document was determined to be authentic, valid and current, therefore, her identity was verified by the agent in accordance with the method. However, although the licence has not yet expired, it is not acceptable to rely on the information from the agent now because the agent's information is about Jane Rogers, and this does not match the name of your client who is now Jane Smith, so the information provided by the agent is not valid and current.

Example 3 — Not acceptable

Jane Smith would like to carry out a transaction for which you must verify her identity. Your agent—with whom you have a written agreement for this purpose—verified Jane Smith's identity in 2019 by referring to her driver's licence, which expired in 2018. In 2019, because Jane Smith's driver's licence had expired, her identity was not verified in accordance with the government-issued photo identification method. As such, it is not acceptable to rely on the information from the agent.

Record keeping requirements when using an agent or a mandatary

When you verify the identity of a person by using an agent or mandatary, you must keep a record of:Footnote 32

Note: As an RE it is your responsibility to meet your client identification requirements under the PCMLTFA and associated Regulations, even when you use an agent or mandatary to verify the identity of a person on your behalf, or when you rely on the measures previously taken by an agent or mandatary to verify a person's identity.

For example, if your agent verifies the identity of a person using the government-issued photo identification method but they don't refer to an authentic, valid and current photo identification document issued by a federal, provincial or territorial government, or keep the required records after verifying the person's identity, you are still responsible. Specifically, it is your responsibility to ensure that the agent is verifying client identity and keeping the required records in accordance with the PCMLTFA and associated Regulations.

Your compliance program's policies and procedures must describe the processes you follow when you rely on an agent or mandatary to verify a person's identity and how you will ensure that the information is valid and current.

4. Verifying a person's identity if it has been previously verified

You do not need to verify a person's identity for subsequent transactions or activities, as required, if you have already verified the identity of the person using:Footnote 33

You must not have doubts about the information that was previously used to verify the person's identity. If you have doubts, you must verify their identity again using the methods explained in this guidance.Footnote 34

Note: In the context of a business merger or acquisition, you are not required to re-identify the acquired clients if their identities were verified in accordance with the methods in the PCMLTFR at the time the verification took place. As a best practice, you are encouraged to review and update client information (for example, name, address, occupation, etc.), in accordance with your risk assessment process. The acquired clients become the responsibility of the acquiring entity which must ensure compliance with the PCMLTFA and associated Regulations. This includes reviewing any money laundering or terrorist financing risks that may be associated with these clients.

5. How to identify a child

If a child is under 12 years of age, you must verify the identity of one parent, guardian or tutor and record the parent, guardian or tutor's information.Footnote 35 You can rely on the information provided by the parent, guardian or tutor in order to record the child's identification details.

If a child is between 12 and 15 years of age, you can verify their identity by using any of the methods. If this is not possible due to a lack of identification information, you may use a variation of the dual-process method that allows you to:

For example, if the child has a passport you may be able to use it to verify their identity under the government-issued photo identification method. If not, you could rely on the parent's driver's licence to verify the parent's name and their common address, and the child's birth certificate to verify the child's name and date of birth.

6. How to verify the identity of a person who does not have any identity verification documentation or information for a retail deposit account Added on February 22, 2023

In the case of opening a retail deposit account, if a bank cannot verify a person's identity in accordance with one of the methods outlined above, they would still be in compliance with their anti-money laudering/anti-terrorist financing obligations if they opened the account in a way that meets the conditions set out in subsections 627.17(1) and (3) of the Bank Act.

Note: The Bank Act applies to banks, authorized foreign banks and federal credit unions, which are defined as banks under the Act.

For reasons beyond a person's control, they may face barriers in meeting requirements where they must provide proper identification documentation or information. This may be the case for vulnerable populations with barriers to obtaining proper identification such as survivors of human trafficking or victims of domestic abuse.

In specific circumstances, where a person does not have the proper identification documentation or information, a bank must:

Note: The risk-based approach must reflect what is known about the client (i.e., their profile and individual circumstances including the fact that alternate identification was accepted), and that ongoing monitoring should then be commensurate to the risk profile of the client. 

When FINTRAC undertakes compliance activities to ensure reporting entities are meeting their obligations, and observes that this process is used, we will:

Legal reference

Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, SOR/2002-184, section 105(6)

7. How to verify the identity of an entity

You can use any of the 3 methods described below to verify the identity of an entity:

  1. 7.1 Confirmation of existing method
  2. 7.2 Reliance method
  3. 7.3 Simplified identification method

While an entity can be a corporation, a trust, a partnership, a fund, or an unincorporated association or organization, corporations are subject to different requirements than other entities (as explained below).

7.1 Confirmation of existence method

Corporation

To verify the identity of a corporation, you may refer to:Footnote 37

The record you refer to must be authentic, valid and current.Footnote 38

You may obtain a corporation's name and address and the names of its directors from a publicly accessible database, such as a provincial or federal database like the Corporations Canada database, or a corporation search and registration service through subscription.

When a corporation is a securities dealer, you do not need to confirm the names of its directors when you confirm its existence.Footnote 39

Entity

To verify the identity of an entity other than a corporation, you may refer to:Footnote 40

The record you refer to must be authentic, valid and current.Footnote 41

Record keeping requirements when verifying the identity of a corporation or other entity

If you refer to a paper record or an electronic version of a record, you must keep the record or a copy of it.

If the electronic version of the record that you refer to is contained in a database that is accessible to the public, you must keep a record that includes the corporation or other entity's registration number, the type of record referred to and the source of the electronic version of the record.Footnote 42

Your compliance program's policies and procedures must describe the processes you follow when using the confirmation of existence method to verify the identity of corporations and other entities, and how you will ensure that the information is authentic, valid and current.

7.2 Reliance method

You may verify the identity of a corporation or other entity by relying on the measures that were previously taken by:

Measures previously taken by an affiliated foreign entity

To rely on measures previously taken by an affiliated foreign entity, you must be satisfied, after considering the risk of a money laundering or terrorist activity financing offence in the foreign state in which it carries out its activities, that:Footnote 45

Measures previously taken by another reporting entity or an affiliated foreign entity

To rely on the measures previously taken by another RE or an affiliated foreign entity to verify the identity of a corporation or other entity, you must:Footnote 46

Your compliance program's policies and procedures must describe the processes you will follow when using the reliance method to verify the identity of corporations and other entities and how you will ensure that the information is valid and current.

7.3 Simplified identification method

If you are an RE that is referred to in any of paragraphs 5(a) to (g) of the PCMLTFA, you may use the simplified identification method to meet your obligation to verify the identity of a corporation or other entity. Specifically, you are deemed to comply with your requirement to verify the identity of a corporation or other entity if, based on your risk assessment, you consider there is a low risk of a money laundering offence or terrorist activity financing offence, and if:Footnote 50

If you subsequently consider, based on your risk assessment, that the risk of a money laundering offence or terrorist activity financing offence has increased and is no longer low then you must, as soon as feasible, verify the identity of the corporation or other entity, as the case may be, by referring to the appropriate records, as explained in section 7.1, Confirmation of existence method.Footnote 51

Record keeping requirements for the simplified identification method

If you use the simplified identification method to verify the identity of a corporation or other entity, you must keep a record that sets out:

Your compliance program's policies and procedures must describe the processes you follow when using the simplified identification method to verify the identity of corporations and other entities.

8. Verifying the identity of an entity if it has been previously verified

You do not need to verify the identity of a corporation or other entity for subsequent transactions or activities, as required, if you have already verified their identity by using: Footnote 53

You must not have doubts about the information that was previously used to verify the identity of the corporation or other entity. If you have doubts, you must verify identity again using the methods explained in this guidance.Footnote 54

9. Restrictions on the use of personal information

The use of personal information in Canadian commercial activities is protected by the Personal Information Protection and Electronic Documents Act (PIPEDA), or by similar provincial legislation. You have to inform clients about the collection of their personal information. However, you do not have to inform them when you include their personal information in the reports you are required to submit to FINTRAC.

The Office of the Privacy Commissioner of Canada can provide further guidance, and has created a Question and Answer document about PIPEDA and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, to help clarify your responsibilities under PIPEDA.

Annex 1: Summary of the methods to identify persons and associated record keeping obligations

Identification method Documents or information to review Identification details that must match Information that must be recorded
Government-issued photo identification Photo identification document issued by a government (not a municipal government) that is authentic, valid and current Name and photograph
  • Person's name
  • Date of verification
  • Type of document
  • Document number
  • Province or state and country that issued the document
  • Expiry date (if applicable)
Credit file Valid and current information from a Canadian credit file that has been in existence for at least three years where information is derived from more than one source Name, address and date of birth
  • Person's name
  • Date you consulted/searched the credit file
  • Name of the credit bureau or third party vendor
  • Person's credit file number
Dual-process Valid and current information from two different reliable sources where neither the RE nor the person is a source

A combination of two of the following:

  • name and address;
  • name and date of birth; or
  • name and confirmation of a financial account
  • Person's name
  • Date you verified the information
  • Name of the two different sources used to verify the identity of the person
  • Type of information referred to
  • Account number or number associated with the information if no account number exists
Affiliate or member Information in the records of the affiliate or the member for the method used Name, address and date of birth
  • Person's name
  • Date you verified the identity of the person
  • Name of affiliate or member that previously verified the identity of the person
  • Method used by the affiliate or member to verify the person's identity
  • Information that the affiliate or member recorded based on the method used
Reliance
  • Be satisfied that the information from the other RE or affiliated foreign entity is valid and current and that the person's identity was verified by using the government-issued photo identification, credit file or dual-process methods or
  • Where the identity was verified prior to June 1, 2021, that the person's identity was verified using one of the methods in force in the PCMLTFR at that time

The identification details listed under the identification method used

  • Person's name
  • The written agreement or arrangement with the other RE or affiliated foreign entity for the purpose of verifying a person's identity
  • The information provided by the other RE or affiliated foreign entity that they referred to in order to verify the identity of the person

Annex 2: Summary of who can identify a person on your behalf

Who Documents or information to review Identification details that must match Information that must be recorded
Agent or mandatary that:
  • Acts for you
  • Previously acted in their own capacity, or acted as an agent or mandatary under a written agreement or arrangement with another person or entity for the purposes of verifying identity
  • Be satisfied that the information is valid and current and that the person's identity was verified using one of the government-issued photo identification, credit file or dual-process methods or
  • Where the identity was verified prior to June 1, 2021, that the person's identity was verified using one of the methods in force in the PCMLTFR at that time 
The identification details listed under the identification method used
  • Person's name
  • The written agreement or arrangement with the agent or mandatary for the purpose of verifying a person's identity
  • All of the information the agent or mandatary referred to when verifying the person's identity
  • The information obtained from the agent or mandatary that they confirmed as being that of the person

Annex 3: Summary of methods to identify an entity and associated record keeping obligations

Identification Method Documents or information to review Identification details that must match Information that must be recorded
Confirmation of existence
  • Information that is authentic, valid and current

For an entity (other than a corporation):

  • partnership agreement
  • articles of association
  • the most recent version of any other record that confirms its existence and contains its name and address

For a corporation:

  •  certificate of incorporation
  • record that has to be filed annually under provincial securities legislation
  • the most recent version of any other record that confirms the corporation's existence and contains its name and address and the names of its directors
  • Name and address
  • Names of Directors (for corporation only)

If you consulted an electronic record from a publicly accessible database:

  • registration number;
  • type of document consulted; and
  • source of the electronic document.

If you consulted a paper record or an electronic record:

  • the paper record, or a copy of the record.
Reliance
  • Verify that information from the other RE or affiliated foreign entity is valid and current and that the entity's identity was verified by using the confirmation of existence method
  • Where the identity was verified prior to June 1, 2021, that the entity's identity was verified using one of the methods in force in the PCMLTFR at that time 
  • Name and address
  • Names of Directors (for corporation only)
  • Entity's name
  • The written agreement or arrangement with the other RE or affiliated foreign entity for the purpose of verifying an entity's identity
  • The information provided by the other RE or affiliated foreign entity that they referred to in order to verify the identity of the entity
Simplified identification

(This method can only be used if you are an RE that is referred to in any of paragraphs 5(a) to (g) of the PCMLTFA.)

  • Risk assessment to confirm that the risk of a money laundering offence or terrorist activity financing offence is low
  • Information to satisfy that the entity exists and that every person who deals with you on behalf of the entity is authorized to do so
N/A but this method can only be used to verify the identity of specific entities
  • The grounds for considering that there is a low risk of a money laundering offence or terrorist activity financing offence
  • The information obtained about the entity and persons to satisfy that it exists and that the persons you deal with are authorized to act on behalf of the entity

Annex 4: Examples of acceptable photo identification documents

The following list provides examples of acceptable government-issued photo identification documents from federal, provincial or territorial authorities. This is not an exhaustive list.

Type of card or document Issuing province or state and country
Canadian passport Canada
Permanent resident card Canada
Citizenship card (issued prior to 2012) Canada
Secure Certificate of Indian Status Canada
Driver's licences
British Columbia Driver's Licence British Columbia, Canada
Alberta Driver's Licence Alberta, Canada
Saskatchewan Driver's Licence Saskatchewan, Canada
Manitoba Driver's Licence Manitoba, Canada
Ontario Driver's Licence Ontario, Canada
Québec Driver's Licence Québec, Canada
New Brunswick Driver's Licence New Brunswick, Canada
Nova Scotia Driver's Licence Nova Scotia, Canada
Prince Edward Island Driver's Licence Prince Edward Island, Canada
Newfoundland and Labrador Driver's Licence Newfoundland and Labrador, Canada
Yukon Driver's Licence Yukon, Canada
Northwest Territories Driver's Licence Northwest Territories, Canada
Nunavut Driver's Licence Nunavut, Canada
DND 404 Driver's Licence Department of National Defence, Canada
Provincial services cards
British Columbia Services Card British Columbia, Canada
Provincial or territorial identity cards
British Columbia Enhanced ID British Columbia, Canada
Alberta Photo Identification Card Alberta, Canada
Saskatchewan Non-driver photo ID Saskatchewan, Canada
Manitoba Enhanced Identification Card Manitoba, Canada
Ontario Photo Card Ontario, Canada
New Brunswick Photo ID Card New Brunswick, Canada
Nova Scotia Identification Card Nova Scotia, Canada
Prince Edward Island Voluntary ID Prince Edward Island, Canada
Newfoundland and Labrador Photo Identification Card Newfoundland and Labrador, Canada
Northwest Territories General Identification Card Northwest Territories, Canada
Nunavut General Identification Card Nunavut, Canada
Types of card or international document
Global Entry Card United States
NEXUS United States or Canada
France driver's licence France
Australian passport Australia
Pennsylvania driver's licence Pennsylvania, United States

Note: You cannot use a provincial health card for identification purposes where it is prohibited by provincial legislation to use the card as a form of identification or to record the health card number.

Annex 5: Examples of reliable sources of information for the dual-process method

This is not an exhaustive list. You must always rely on valid and current information, whether it be through an original version or whether you obtain another version of the information's original format, such as a fax, photocopy, scan, or electronic image, and that can meet your related record keeping obligations.

Reliable sources of information to verify name and address Reliable sources of information to verify name and date of birth Reliable sources of information to verify name and confirm a financial account (specifically, a deposit account, prepaid payment product account, credit card account or loan account)

Issued by a Canadian government body:

  • A fax, photocopy, scan or electronic image of a government-issued photo identification document
  • Any statement, form, certificate or other source issued by a Canadian government body (federal, provincial, territorial or municipal):
    • Canada Pension Plan (CPP) statement
    • Property tax assessment issued by a municipality
    • Provincially issued vehicle registration
  • Benefits statement:
    • Federal, provincial, territorial, or municipal levels

Issued by other Canadian sources:

  • Utility bill (for example, electricity, water, telecommunications)
  • Canada 411
  • Record of Employment
  • Registered investment account statements (for example, RRSP, TFSA or RRIF)
  • Canadian credit file that has been in existence for at least six months
  • Product from a Canadian credit bureau or other third party (containing two trade lines in existence for at least six months)
  • Insurance documents (home, auto, life)
  • For a currently enrolled student, a transcript or documentation issued by a school that contains a unique reference number

Issued by a Canadian government body:

  • A fax, photocopy, scan or electronic image of a government-issued photo identification document
  • Any statement, form, certificate or other source issued by a Canadian government body (federal, provincial, territorial or municipal):
    • Birth certificate
    • Marriage certificate or government-issued proof of marriage document (long form which includes date of birth)
    • Divorce documentation
    • Permanent resident card
    • Citizenship certificate
    • Temporary driver's licence (non-photo)

Issued by other Canadian sources:

  • Canadian credit file that has been in existence for at least six months
  • Product from a Canadian credit bureau (containing two trade lines in existence for at least six months)
  • Investment account statements (for example, RRSP, GIC)
  • Insurance documents (home, auto, life)

Issued by a foreign government:

  • Travel visa
  • A fax, photocopy, scan or electronic image of a photo identification document issued by a foreign federal, provincial or territorial government (for example, foreign driver's licence or passport)

Confirm that the person has a deposit account, prepaid payment product account, credit card or loan account by means of:

  • Credit card statement
  • Bank statement for deposit or chequing accounts
  • Loan account statement (for example,  mortgage)
  • Cheque that has been processed in the last statement period (cleared, insufficient funds) by a financial institution
  • Telephone call, email, letter, or other traceable means of confirmation from the financial entity holding the deposit account, prepaid payment product account, credit card or loan account
  • Product from a Canadian credit bureau (containing two trade lines in existence for at least six months)
  • Use of micro-deposits

Details and history

Published: June 2021

List of changes and updates
Date
[YYYY-MM-DD]
Summary of changes
2023-08-02
  • Added link to video 5 "Verifying the identity of a client: Reliance method"
2023-05-11
  • Added link to video 4 "Verifying the identity of a client: Affiliate or member method"
2023-03-22
  • Added link to video 3 "Verifying the identity of a client: Dual-process method"
2023-02-22
  • Added section 6 "How to verify the identity of a person who does not have any identity verification documentation or information for a retail deposit account"
  • Modified layout of the guidance
2023-01-26
  • Added link to video 1 "Verifying the identity of a client: Government-issued photo ID method"
  • Added link to video 2 "Verifying the identity of a client: Credit file method"

For assistance

If you have questions about this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

Date Modified: